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One story dominated the week, and it carries obligations that travel with the product across every checkout. The EU's consumer-protection network escalated its scrutiny of how games sell in-game currencies, while industry trade bodies disputed the legal basis and offered their own set of commitments. For publishers building out-of-app commerce, the dispute's likely baseline matters more than its eventual resolution.
EU consumer authorities open coordinated action over in-game currency sales; industry disputes legal basis
The EU's Consumer Protection Cooperation (CPC) Network, coordinated by the European Commission, launched coordinated enforcement actions against eleven games companies over how they sell and handle in-game virtual currencies. Named companies include King, Supercell, Mojang, Riot Games, Activision Blizzard, Ubisoft, Crytek, InnoGames, Plarium Europe and PLR Worldwide Sales. In a joint statement published September 30, 2026, the network said a high number of companies had made no substantive changes since it issued non-binding "Key Principles" on in-game currencies in March 2025, and focused on variable-reward systems such as loot boxes, "dark patterns", and practices that directly exhort children to spend. The same day, Video Games Europe and the European Game Developers Federation pushed back, disputing the classification of in-game currencies as "digital representations of value" and citing a European Court of Justice ruling on RuneScape's currency; they set out six commitments, including clearer real-money pricing, 48-hour refunds for wholly unused bundles even where withdrawal rights are waived, 30 days' notice before removing purchased content, and child-safety measures, conditional on the legal uncertainty being resolved.
Why it matters: These conduct obligations attach to how virtual currency is priced, bundled, refunded and marketed, so they travel with the product into a publisher's own web shop or top-up flow, not just the app stores. The six industry-proposed commitments are a practical design checklist for any out-of-app currency sale — real-money pricing shown next to packs, a working unused-bundle refund path, and minor-purchase safeguards — whichever way the classification dispute lands.
- mobilegamer.bizOct 1, 2026
- European CommissionSep 30, 2026
- Video Games EuropeSep 30, 2026
The takeaway
This week's pattern is that consumer-law expectations for in-game currency are converging toward a concrete baseline — pricing transparency, refund SLAs and minor-purchase controls — well ahead of any settled legal classification. Publishers running or planning out-of-app checkout should treat the industry's own commitment list as a specification to build against now rather than waiting for the dispute to close. From tokenz's Merchant-of-Record vantage, the channel that gives publishers the most control over price display, refunds and age-gating is also where these rules are cleanest to implement by design, and a seller-of-record model is one way to shift the underlying consumer-law, refund and tax liability off the publisher as DTC scales.
